Words and Phrases - "credited"
12 June 1996 External T.I. 9619795 - MEANING OF "PAID OR CREDITED"
"An amount is 'credited' where a resident of Canada has set aside and made unconditionally available to the non-resident creditor an amount due to the non-resident. An amount is unconditionally available to the non-resident person when the non-resident has the immediate right to receive the amount, for example, when the amount is recorded in the payer's books and is payable on demand." It was quite possible that no amount would be considered to have been paid or credited to a U.S. resident where the question of ownership of the relevant property was subject to litigation.
Words and Phrases
credited